Comment Log Display

RE: Comments on 2030 Scoping Plan Update, December 2, 2016

Energy Efficiency: As mentioned in the plan cleaner and more
efficient technologies, new polices an incentives that better
recognize and reward innovation and prioritize low carbon
investments. As mentioned SB 375 is one of the ways to address
housing and transportation needs and provide climate benefits.  AB
32 Scoping plan can expand this effort by assessing and addressing
the energy-related and non-energy benefits of accelerating energy
efficiency efforts in existing homes, where much of California's
GHG emissions come from.  Without some careful analysis and
consideration of this opportunity, stakeholders and the public in
general cannot evaluate how well the draft Scoping Plan will meet
the goals for 50% energy use reduction and weatherization of all
eligible homes, and improvements in human health and environmental
equity.  

The co-benefits of energy efficiency in existing building also
directly correlate to improved living conditions, reduced stress,
and reduction in fuel poverty. In the SB 350 barrier repot it is
recommend that a common set of NEB’s should be defined along with
metric to measures them and should be integral to delivery of
energy services for low income communities. In a recently published
study Occupant Health Benefit of Residential Energy Efficiency
(November 2916), it was demonstrated that residential energy
efficiency programs that typically improve the building envelop and
HVAC systems creating more comfortable homes, improve the
environmental conditions and the occupant health including reduced
hospital visits.  The plan should look to capture and identify
these avoided social costs of energy efficiency and support
innovative approaches to achieve the co-benefits. 

One of California's goals is to reduce energy use in existing
buildings by 50% by 2030. As noted in the plan (on page 30) Zero
Net Carbon Building is an important strategy to achieve our 2050
target, but requires work needs to start now. In that vein, the
scoping plan should look to accelerate efforts in the following
areas to take advantage of the GHG reduction opportunities in the
existing building stock.  The plan should evaluate the
opportunities to increase energy efficiency in existing buildings
to achieve our 50% reduction target including but not limited to
the following examples: 

•	Explore cost effective ways to reduce GHG emission from a large
number of stationary source of CO2 such as furnaces, boilers and
water heaters.
•	Identify opportunities to be more aggressive and streamlined ways
of weatherizing moderate income homes should be demonstrated and
pursued immediately.
•	Demonstrate the opportunity for green building programs to
achieve greater reductions in GHGs associated with efforts beyond
energy efficiency including overall reduction in energy use, water
and resource conservation and waste reduction (possibly in Appendix
G in 2017)
•	Support local government initiatives to achieve improvements in
existing residential sector.  Owner – occupied homes can be
addressed through requirements at time of sale such as Portland and
Berkeley have done.  The city of Boulder addressed it rental
housing stock through and ordinance to achieve an energy efficiency
threshold by a date certain. 
In light of the potential reduction in federal support for low
income weatherization programs in the near future, California may
need to expand support to these efforts through other sources in
order not to fall shorter of its GHG reduction targets and climate
adaptation than planned. 

Electrification: The plan also identifies the importance of
reducing consumption and reliance on natural gas.  We understand
that we must decarbonize our fuel source in order to meet
greenhouse gas emission goals.  In this vein, it is recommended
that ARB include additional measures to support the decarbonization
of our buildings when carbon pricing itself will not be effective. 
The new policy in Alternative 1 is highly supported, but this
option must be coupled with additional actions to have the intended
impact on the market.  While the technology in the market is
increasing, there is a need to make the technology more
accessible/affordable, less risky, and more available.  In
addition, the energy code and the CPUC rule set for fuels switching
prevent the electrification of existing homes. ARB should evaluate
the scenarios and existing regulation and programs to ensure there
are mechanisms to support intended outcomes of carbon reduction.
The actions should support fuels switching in existing homes and
all electric new homes that will be leveraging a cleaner source of
electricity under the RPS. 

Resiliency: Please consider the opportunity to include resilient
design measures for extreme heat and other anticipated climate
changes that will affect the most vulnerable populations. Our
current building model does not take into account these future
impacts and would not address the ability of a building to be
thermally comfortable in an extreme heat wave or increased
durations of heat waves, as an example. LEED and GreenPoint Rated
as green building certification programs have included
vulnerability assessments and improvements to address climate
adaptation in addition to social equity measures.